Colorado’s Producer Responsibility Advisory Board has received an initial plan proposal from an organization offering to run the state’s extended producer responsibility (EPR) law.
Circular Action Alliance (CAA) submitted its initial plan proposal that details program operations and describes how CAA will help producers comply with all elements of the law, according to a news release from CAA.
“Additionally, the plan incorporates extensive feedback solicited by CAA during a robust consultation process that engaged more than 2,000 representatives of Colorado business, government, trade association, and nonprofits,” according to the organization.
EPR laws require producers to pay dues to fund the costs of collection, sortation, and processing of packaging and paper. Once fully implemented, the state program is projected to expand access to recycling services for to up to 700,000 Colorado households and nearly double the recycling rate for paper and packaging in Colorado.
Details and Timelines
The plan details include the following:
- Producer Compliance: This describes how CAA tracks compliance among producers and collaborates with the Colorado Department of Public Health and Environment (CDPHE) to bring producers into compliance.
- Minimum Recyclables List: This provides a uniform statewide list of recyclable materials that must be collected in a manner that is as convenient as the collection of solid waste.
- Post-Consumer Recycled Content (PCR): This sets targets for minimum PCR content rates for certain types of covered materials, including paper, glass, metal, and plastic, that the state will strive to meet by January 1, 2030, and January 1, 2035.
- Collection and Recycling Rate Targets: This sets 2030 and 2035 collection and recycling rates.
- Dues Schedule and Budget: This describes CAA’s approach to dues setting, including eco-modulation of dues.
- Reimbursement for Service Providers: This describes how CAA will reimburse participating service providers for 100% of the net recycling services costs.
- Reuse and Refill: This proposes an approach to measure and report on the use of reusable and refillable covered materials and establishes goals and strategies for increasing reuse and refill.
- Education and Outreach: This proposes an approach for a statewide education and outreach program.
- Responsible End Markets: This ensures any covered materials collected for recycling will be transferred to a responsible end market.
Next Steps
“Collaboration was critical in developing a proposal that will ultimately increase Colorado’s recycling rates for packaging and paper,” said Juri Freeman, executive director of CAA Colorado, in a statement.
“While there are several steps yet to reach a finalized plan, we look forward to driving Colorado’s circular economy through continued collaboration.”
Colorado’s Producer Responsibility Advisory Board—created as part of the law and composed of 13 industry experts—has 90 days to review the plan for compliance with the law and provide feedback.
CAA has 60 days to respond after which the advisory board must forward the plan to CDPHE with its recommendation for approval or rejection.
CDPHE is expected to open public comment from September through December 2025.
If the full timeline is utilized and CDPHE approves the plan, that approval would occur near the end of December 2025, with program implementation beginning in 2026. If the plan is rejected, CAA has 60 days to resubmit the plan and start the process again.